HomeMy WebLinkAboutItem 7a. Consider Recommendation to approve Pre-Litigation Settlement of CVRA District Election Demand Item 7a
Department: Attorney
Cost Center: 1501, 1001, 1021
For Agenda of: 11/19/2024
Placement: Business
Estimated Time: 120 Minutes
FROM: Christine Dietrick, City Attorney
Marguerite Leoni, outside Legal Counsel
SUBJECT: CONSIDER RECOMMENDATION TO APPROVE PRE-LITIGATION
SETTLEMENT OF CALIFORNIA VOTING RIGHTS ACT DISTRICT
ELECTION DEMAND
RECOMMENDATION
1. Approve a tentative settlement agreement and related settlement documents to
resolve the February 17, 2023 California Voting Rights Act District Election Demand
(CVRA Demand) served on the City by Kevin Shenkman on behalf of S outhwest Voter
Registration Education Project (SVREP), including:
a. Settlement Agreement
b. Draft CVRA Complaint to be filed by SVREP alleging CVRA violations
c. Draft City Answer to Complaint denying CVRA allegations
d. Stipulated judgment directing transition to Citywide Single Vote Council elections,
beginning November 2026
2. Authorize the Mayor, City Attorney and City Manager to execute and file documents
and take administrative actions necessary to implement the Settlement Agreement.
3. Appropriate $75,000 from the Fiscal Year 2023-24 General Fund Undesignated Fund
Balance to be used for SVREP Attorneys' fees to date as described in the settlement
agreement.
REPORT-IN-BRIEF
The purpose of this report is to seek final approval of a pre -litigation settlement package
with SVREP in response to a California Voting Rights Act (“CVRA”) demand letter served
on the City by attorney Kevin Shenkman on behalf of his client SVREP on Febru ary 17,
2023. Staff is requesting Council confirmation that the package of settlement documents
fully and accurately reflects and implements Council direction provided during closed
session litigation settlement discussions and that the settlement terms are consistent with
the settlement authority provided to staff by the Council. If approved, the settlement will
result in the City transitioning to a “Citywide Single Vote” model for electing
Councilmembers, beginning in the 2026 election cycle. In short, this would mean that the
City would move from the current “vote-for-two candidates to elect two Councilmembers”
model, to a “vote-for-one candidate to elect two Councilmembers” model, whereby the
top two candidates receiving the most single votes are elected to Council.
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The City has been served with two demand letters under CVRA since November 2019,
the first of which was resolved in 2022, with out litigation and with no electoral structure
changes.
To date, the City of Santa Monica is the only California city to have prevailed in its defense
of a CVRA litigation demand at the appellate court level (after appealing a trial court ruling
against the city); however, in September 2023, the California Supreme Court reversed
that appellate court victory. The litigation has been ongoing for approximately eight years
and is continuing. As of the date of this report, the case has been remanded back t o the
trial court that originally ruled against the City of Santa Monica, prompting the city’s
appeal, and there is a pending motion by the plaintiffs to update and reinstate the trial
court ruling against the city (see full timeline with links to court filings here:
santamonica.gov - Santa Monica Election Litigation). Santa Monica has expended
millions of dollars in attorneys’ fees for its own defense (which would not be re coverable
by the city even if it ultimately prevailed) and, at present, the city remains exposed to a
prevailing party attorneys’ fees award of tens of millions of dollars in the event the ruling
in favor of plaintiffs ultimately becomes final.
The current demand letter served on the City of San Luis Obispo arose in the context of
the Santa Monica litigation, and SVREP’s attorney, Kevin Shenkman, is also the plaintiffs’
counsel in the Santa Monica case. Notwithstanding that context, the City of San Luis
Obispo concluded, based on its data analyses related to the first CVRA demand letter it
received, and as subsequently updated, that San Luis Obispo is significantly differently
situated from Santa Monica as it relates to voter equity concerns under CVRA a nd the
ability to prove a CVRA violation under the City’s current at-large election structure.
Specifically, it is the City’s position that the City of San Luis Obispo demographics, Latinae
voter dispersion, community-wide coalition building capacity, candidate election history,
and City commitments to and investments in advancing its Diversity, Equity and Inclusion
Major City Goal programs support a conclusion that the City’s electoral system is not
encumbered by the type of discriminatory racial polariza tion or minority vote dilution that
CVRA seeks to remediate.
As a result of the City’s analyses, the City requested, and Mr. Shenkman and his client
agreed, to toll the generally applicable statutory timelines under the CVRA in order to
facilitate data sharing and discussion of alternatives to litigation or a move to district voting
for City elections. At Council’s direction, as part of confidential settlement negotiations,
staff shared with Mr. Shenkman both election data analysis and information regar ding
City initiatives to advance equity. Following ongoing direction from the City Council
received in Anticipated Litigation Closed Sessions, City staff, outside counsel, and Mr.
Shenkman engaged in a series of information exchanges and highly constructive
settlement discussions that have resulted in the settlement package that is now
recommended for Council approval.
Throughout settlement discussions, the parties focused on the following:
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1. Data based discussions and proposals regarding the efficacy of d istrict elections
to advance, in San Luis Obispo, the purpose and intent of CVRA.
2. Viable alternatives to district elections that could more effectively advance CVRA
objectives in the specific context of San Luis Obispo.
3. SVREP’s primary objective to achieve a structural change in the City’s method of
electing Councilmembers as a condition of any settlement.
4. Implementation of provisions that align with and advance City Diversity, Equity and
Inclusion goals.
5. Advancement of enhanced voter education, outreach and participation goals.
6. Further refinement of the proof necessary to support a CVRA lawsuit and guidance
regarding potential alternatives to district elections that was provided by the
California Supreme Court decision in the Pico Neighborhood Association and
Maria Loya v. City of Santa Monica case.
7. Dispute resolution processes designed to facilitate ongoing collaboration between
the parties and avoid future litigation over disagreements in data analysis or
conclusions related to future elections.
8. A mechanism (stipulated judgment) by which to assure court oversight and
ongoing jurisdiction over the proposed settlement.
The components of the tentative settlement negotiated over nearly two years include:
1. Agreement that the City will transition its current at large “vote for two to elect two”
Council Members election process to a single vote, “vote for one to elect two”
system, to be called “Citywide Single Vote” beginning with the November 2026
election and in all subsequent elections.
2. Agreement to share data and analyses following the 2026 and 2028 elections to
evaluate the effectiveness of the new system as compared to a hypothetical district
election model proposed by Mr. Shenkman.
3. A process by which the Council will consider a transition to district elections if
subsequent data analyses following the 2026/2028 elections supports that the
purpose and objectives of CVRA are not being achieved under the Citywide Single
Vote model and would be achieved under the hypothetical distr ict election model.
4. A dispute resolution process if the parties cannot agree on the conclusions
reached from 2026/2028 post-election data analyses and/or if the Council declines
to implement districts that both parties concur are supported by the data analyses.
5. Limitation of costs and plaintiffs’ attorneys’ fees to be borne by the City related to
agreed upon dispute resolution processes.
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6. Agreement that SVREP will not be required to serve a subsequent demand letter
on the City, and that the City will waive any objection to the standing of SVREP to
sue, in the event that all dispute resolution processes under the settlement
agreement are exhausted without resolution and SVREP determines it needs to
proceed with a CVRA lawsuit following the outcome of the 2026 /2028 elections
analyses and settlement processes.
7. City commitment to voter education and outreach efforts and programs to enhance
diverse candidate and voter education, development, and participation in local
elections.
8. Ability of the City to implement district elections at any time it may determine
districts to be an effective structure for the City based on evolving data and
demographics analysis, and to be relieved of future obligations under the
settlement agreement in the event the City does transition to districts.
9. Payment of attorneys’ fees ($75,000) to SVREP to compensate for its costs of
participation to date in negotiations with the City to avoid litigation.
10. Agreement to limited payments to SVREP to offset its costs of participation in
future data analyses of the 2026/28 elections and support it may provide to the
education and outreach efforts (not to exceed $10,00 per election cycle).
While the Council could have approved the settlement agreement in a closed session
meeting, Council instead directed staff to place the final approval of the proposed
settlement on a public meeting agenda to provide transparency as to the terms of the
proposed agreement and the process by which tentative agreement was reached, and to
facilitate an open community discussion on this important local election process change.
Staff is aware that there have been community discussions of alternatives to the Citywide
Single Vote system proposed in the settlement, including the potential to consider ranked
choice or cumulative voting. For reasons discussed in greater detail below, those
alternatives were considered during settlement negotiations and rejected in favor of the
current Citywide Single Vote proposal.
While public comment and feedback on the proposed settlemen t terms are being sought
through this Council agenda item, it is important to keep in mind that the terms being
proposed are the product of lengthy and extensive settlement negotiations focused on
avoiding costly and time-consuming litigation. Any significant changes to the negotiated
terms cannot be imposed upon the plaintiffs and could remove any litigation protections
the City would have under the terms of the agreement. In other words, significant
substantive changes to the terms of the proposed agreement may result in SVREP filing
a lawsuit against the City. Additionally, the parties agree that the recommended proposal
presents a mutually beneficial opportunity to enhance equity and participation among both
candidates and voters in the City’s local elections. Therefore, staff recommends that the
Council approve the proposed settlement package.
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Staff suggests that any alternatives or considerations of interest to the community that
may emerge from public meeting comments be addressed via direction to staff to pursue
subsequent discussions with SVREP as follow-up conversations following approval of the
current negotiated settlement. Alternatively, Council could direct staff to complete further
analysis and return to Council for further presentation of information regarding other
alternatives, subject to ongoing compliance with the settlement terms.
POLICY CONTEXT
State Law
The California Voting Rights Act (“CVRA”), enacted in 2002, and codified as California
Elections Code, Section 14027-14032, is a law enacted by the California State Legislature
to provide minority groups in California a legal tool to address claims that their votes are
being diluted by “at-large” elections in which all members of a community vote for all
candidates for local offices. CVRA is similar to but expanded upon, and lessened the
burden of proof for similar claims under, the Federal Voting Rights Act of 1965 (FVRA).
CVRA makes it easier for plaintiffs under the state law to prove vote dilution than under
federal law.
Under federal law, as interpreted by various court cases, a plaintiff under the FVRA must
prove: that the affected minority group is sufficiently large to elect a representative of its
choice; that the minority group is politically cohesive ; and that white majority voters vote
sufficiently as a bloc to usually defeat the minority group's preferred candidates . CVRA
does not require plaintiffs to demonstrate a specific geographic district where a minority
is concentrated enough to establish a majority. Rather, the CVRA invalidates not only at-
large elections that prevent minority voters from electing their chosen candidates, but also
those that impair the ability of minority voters to influence elections. “Ability to influence”
is not defined under CVRA and the California Supreme Court recently declined to define
the term more precisely in its ruling in a CVRA case against the City of Santa Monica.
In 2016, following a significant volume of litigation against cities under CVRA resulting in
significant attorneys’ fees awards against even cities that opted to transition to district
elections, the California legislature passed legislation amending Section 10010 of the
Elections Code to provide a 45-day “safe harbor” limit after the receipt of a letter from
potential plaintiffs in CVRA cases. The amendment prevents lawsuits during the 45 -day
period. If the city makes legal moves towards district elections during that 45-day period,
it cannot be sued for an additional 90 days after it makes a legal declaration. Th e city
must then hold at least two public hearings on the matter within 30 days. The amendments
to Section 10010 also put a limit [initially $30,000, increased by CPI annually, now roughly
$38,000] on the amount the city must pay to potential litigants if the city moves to district
elections within the 90-day period. If a city declines to adopt a resolution of intent to
transition to district elections, or thereafter fails to complete the process to implement
districts, the city becomes subject to litigation and there is no limitation on the attorneys’
fees that can be recovered by the plaintiff who served the demand, if they prevail.
Litigation fee awards in these cases have ranged generally in the millions of dollars. For
example, the fee award in the CVRA case against the City of Highland, which was on
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remedy only, was about $1 million; the award against the City of Modesto was $3.5
million; the award against the City of Palmdale was $4.5 million. Plaintiffs in the CVRA
action against the City of Santa Monica are reportedly seeking $22 million for legal
services through trial. The CVRA and Section 10010 also apply to charter cities, but the
section's application to enable charter cities to use an ordinance to go to district elections
where the charter provides for at large elections (such as would be applicable to the City
of San Luis Obispo), has not been finally resolved by courts.
Santa Monica Supreme Court Case
As noted above, the California Supreme Court recently considered the scope of CVRA in
the case of Pico Neighborhood Assn. v. City of Santa Monica, in which the Court
explained “We granted plaintiffs' petition for review to determine what constitutes dilution
of a protected class's ability to elect candidates of its choice or to influence the outcome
of an election within the meaning of the CVRA.” Pico Neighborhood Assn. v. City of Santa
Monica, 15 Cal. 5th 292, 310, 534 P.3d 54, 61 (2023), as modified (Sept. 20, 2023).
The Court ultimately held as follows:
A group's ability “to compete successfully at electoral politics, in short, is often
dependent on how the competition is structured.” (Engstrom, supra, 21 Stetson
L.Rev. at p. 743.) The CVRA represents the Legislature's effort to make that
competition more fair. It bars the use of an at-large method of election if that
method dilutes a protected class's ability to elect candidates of its choice or its
ability to influence the outcome of an election. Dilution occurs when an at -large
system denies a protected class the potential to elect its preferred candidate or
influence the election's outcome. The plaintiff in a CVRA action must identify a
lawful alternative to the existing at-large electoral system that will serve as the
benchmark undiluted voting system.
A protected class has the ability to elect its preferred candidate if it would have the
potential to elect that candidate, on its own or with the assistance of crossover
support from other voters, under an alternative voting system; there is no additional
requirement that the protected class constitute a majority or near -majority of a
hypothetical district. A court presented with a dilution claim should undertake a
searching evaluation of the totality of circumstances (see, e.g., Elec. Code, §
14028, subd. (e)), including the characteristics of the specific locality, its electoral
history, and the design and impact of the at-large system as well as the potential
impact of lawful alternative electoral systems. In predicting how many candidates
are likely to run and what percentage may be necessary to win, courts may also
consider the experiences of other similar jurisdictions that use district elections or
some method other than traditional at-large elections.
Pico Neighborhood Assn. v. City of Santa Monica, 15 Cal. 5th 292, 324, 534 P.3d
54, 71 (2023), as modified (Sept. 20, 2023)
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City Charter
The San Luis Obispo City Charter, Section 402-Election at Large, provides:
The Mayor shall be elected at the general municipal election on a general ticket
from the City at large.
The Council Members shall be elected at the general municipal election from the
City at large, two being selected biennially.
The Citywide Single Vote election model, as discussed in more detail in this report and
reflected in the proposed settlement agreement, is still an at-large form of election and its
implementation would not require a Charter amendment. In the absence of an admission
of a CVRA violation (which the City denies) or court adjudication of a CVRA violation
compelling the implementation of district elections as a remedial measure,
implementation of district elections in the City would require a Charter amendment.
Charter amendments must be approved at an election by the voters of the City.
DISCUSSION
Background
In November 2019, the City received its first CVRA demand letter from Robert Goodman,
Attorney-at-Law, on behalf of his client Jamie Gomez. The letter asserted that the City of
San Luis Obispo’s method of conducting elections with at-large voting may violate the
California Voting Rights Act (“CVRA”) and demanded that the City Council adopt a
Resolution of Intent to transition from at-large to district elections.
In response to that first demand, the City retained outside counsel with CVRA expertise,
Marguerite Leoni, and worked with legal counsel and an experienced demographics
consultant to perform independent demographics, vote dilution, and racially polarized
voting analyses. The City also was monitoring the California Supreme Court, Pico
Neighborhood Association v. City of Santa Monica, CVRA case, which was being litigated
by Mr. Shenkman and raised issues pertaining to proof of vote dilution under CVRA that
are of particular relevance to the City of San Luis Obispo.
Based on analyses performed by the City’s expert consultants, the City and Mr. Goodman
agreed to enter into a tolling agreement and engage in settlement discussions. That
demand was ultimately resolved in November 2022 through a settlement that provided
for the payment of minimal attorney’s fees, with no changes to the City’s election
structure.
The City received its second demand letter from Mr. Shenkman and SVREP just a few
months later. Staff and the City’s consultants evaluated the demand, consulted with the
Council in closed session, updated the City’s elections data analysis and requested
discussions with Mr. Shenkman that began a constructive series of negotiations leading
to the current proposed settlement agreement.
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Settlement Discussion Context
Although the City disputed the assertion that the City’s updated demographics, racial
polarization and dilution data supported a conclusion that the City was in violation of
CVRA, the Council did not dismiss SVREP’s demand out of hand, but rather directed staff
to attempt to further explore the basis for the demand with Mr. Shenkman. Based on that
direction, the parties began open discussions regarding the potential alignment between
the City’s Diversity Equity and Inclusion (DEI) efforts, CVRA objectives, and the voter and
candidate equity objectives of Mr. Shenkman’s client, SVREP.
The City initially shared an overview of its prior analysis with Mr. Shenkman and
requested that he share his impressions of the City’s data conclusions. Additionally, the
City shared the Council’s DEI objectives, as well as the City’s efforts to enhance access
to elected office through such steps as increasing the salary of council members, re -
instituting and restructuring a Community Academy to foster interest and educate a more
diverse cross section of residents about city government, and developing and funding a
robust DEI program in city government, including hiring a DEI Manager and staff and
funding programs to enhance diversity, awareness, and access in the community. In that
context, the parties considered the demographics of the City, the relative racial and ethnic
heterogeneity of its neighborhoods, the dispersion of the City’s Latinae population across
the City, and the consequent likelihood of significant dispute as to the ability to create
meaningful opportunities for Latinae eligible voters to elect or influence the election of
chosen candidates through a districting plan. The parties engaged in good faith
negotiations to identify areas of alignment in objectives and measures on which SVREP
and the City could agree would enhance equity in local elections and support the
underlying purposes of CVRA, with an alternative to district elections.
Why Citywide Single Vote?
Citywide Single Vote contrasts with the City’s current voting system, in which a voter can
select as many candidates as there are open seats. As noted above, under the Citywide
Single Vote methodology, City voters would have one fewer vote than the number of
Council seats available. The City would continue with staggered Council elections,
wherein two Council seats with four-year terms would be up for election every two years.
Under the proposed new system, City voters would vote for only one candidate a nd the
top two candidates receiving the most single votes would be elected to serve. This single
vote would also occur if the City were to transition to a vote-by-district system. However,
in a district system, voters would be limited to voting only for a candidate that lives in the
same district in which the voter resides, and would only vote for their single Council
representative every other election year because Councilmembers serve four year terms,
and only one candidate would be elected for each district. In other words, a voter in one
district would have no vote as to which candidate is elected in another district. Under the
Citywide Single Vote structure, all voters would vote for a single Councilmember every
two years and there would be no geographic barriers to Citywide coalition building to
coalesce support around a single candidate.
The purpose of single voting is to prevent the same majority from controlling all of the
available seats and to create opportunities for non-majority groups to build coalitions of
support to elect at least one of their preferred candidates, or at a minimum to prevent the
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election of a non-preferred candidate. Single voting often benefits minority groups that
are not numerous enough to form a majority of the voting p opulation. Voters from the
minority group can focus their single vote on the candidate who best represents their
interests, which can increase the chances that the minority group will have a voice in the
election, especially if the majority is fragmented and does not unite behind a single
candidate.
Single voting is a methodology that has been adopted as an alternative voting method in
the United States in response to Federal Voting Rights Act challenges. Single voting
(sometimes called “bullet voting” or “limited voting”) is currently used for elections in
dozens of jurisdictions across the United States, including many parts of Alabama,
Connecticut, Pennsylvania, and North Carolina. While not formally adopted locally,
several local council candidates over the years have shared that single voting has been
broadly used on an informal basis in past City elections for precisely the purpose stated
above. A review of the past three City elections showed that a significant number of voters
only cast one vote, even under the current structure, when they could have voted for two,
which supports the anecdotal experience of local candidates and voters. In the 2022,
2020 and 2018 elections this “undervote” for City Council was 53%, 41% and 44 %,
respectively.
Further collaboration with the San Luis Obispo County Clerk Recorder’s Office will be
necessary regarding continued consolidated administration of City elections by the
County.
Why Not Districts?
The short answer to this question is that the City could not conclude that the data supports
that implementation of district elections in San Luis Obispo would actually advance the
voter equity objectives underlying CVRA. Additionally, the City’s analyses and
conversations with Latinae leaders throughout the settlement process raised questions
whether implementing districts could actually slow the broader progress on DEI goals the
community has made through City DEI initiatives and investments. There were also
concerns that implementing districts could fracture and inhibit ongoing citywide
community coalition building in a manner that could have the unintended consequence of
diminishing Latinae community influence in the City’s elections.
Additionally, due to the small number of Latinae community members and the fact that
there is no concentration of community members in any particular area of the City, the
traditional data analysis of voter preference yields unreliable results due to extremely high
margins of error and does not yield any clear path to a likely effective districting model.
Since receiving the original Goodman/Gomez demand letter in 2019, the City’s legal
counsel and demographics consultants have evaluated the City’s ability to create a
majority Latinae single-member electoral district. Under the 2020 Census data, the total
population of the City has grown from about 45,173 in the 2010 Census to about 47,160, or
by about 1,987 people. The growth appears to be entirely in the Latinae population which
increased from 6,630 to 8,755 people.
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Latinae residents who are eligible to vote (“Citizens of Voting-Age” or “CVAP”) increased
from an estimate of 12.58% to an estimated 13.45%, but Spanish surnamed registration1
held steady at about 9.43% - 9.70% of registration from November of 2018 to March of 2020.
Even considering the growth in Latinae population, it is not possible to create a majority
Latinae eligible voter (“LCVAP”) district in the City. There are only about seven census
blocks in the City that are over 50% Latinae in eligible voter population, and they are
sufficiently distant from each other that highly irregular boundaries would be required to
include them in a single district. These data are based on the Census Bureau estimates for
the period 2015 – 2019, which were the most recent at the time of publication of the 2020
Census data. The parties agree that the strongest Latinae district that could be formed,
even in a five-district election system, whereby the Mayor would no longer be directly
elected, would be comprised of approximately 21% Latinae residents (see Attachment
E).
The parties disagree on whether reliable evidence of statistically significant racially
polarized voting or identification of clearly Latinae preferred candidates in the City’s past
elections could be produced. However, even assuming sufficient evidence could be
produced, the California Supreme Court recently held that
[t]he existence of racially polarized voting is not, in itself, sufficient for a vote -
dilution claim under the California Voting Rights Act (CVRA) challenging a
nonpartisan at-large voting system, and dilution requires a showing that the
minority group has less ability to elect its preferred candidate or influence the
election's outcome than it would have if the at-large system had not been adopted.
Cal. Elec. Code §§ 14026(a, c), 14027.
***
Accordingly, we agree with the Court of Appeal that dilution is a separate element
under the CVRA. To establish the dilution element, a plaintiff in a CVRA action
must identify “a reasonable alternative voting practice” to the existing at -large
electoral system that will “serve as the benchmark ‘undiluted’ voting practice.”
(Reno v. Bossier Parish School Bd., supra, 520 U.S. at p. 480, 117 S.Ct. 1491.)
Pico Neighborhood Assn. v. City of Santa Monica, 15 Cal. 5th 292, 315, 534 P.3d
54, 65 (2023), as modified (Sept. 20, 2023)
Why Not Ranked Choice or other Cumulative Voting Method?
The Secretary of State is authorized under the California Elections Code to certify voting
systems. Section 19216 states, in relevant part: "If a voting system or a part of a voting
system has been certified or conditionally approved by the Secretary of State, it shall not
be changed or modified until the Secretary of State has been notified in writing and has
determined that the change or modification does not impair its accuracy and efficiency
sufficient to require a re-examination and recertification, or conditional approval, pursuant
to this article." See also Elec. Code 19101. It is the position of the Secretary of State that
1 Staff acknowledges concerns that Spanish surname registration is not a precise proxy for Latinae voter
registration; however, it is nonetheless the standard methodology of identifying Latinae voters in CVRA
litigation.
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any voting system that has not been certified or tested for the purpose for which it is
intended to be used requires at a minimum notification to the Secretary and possibly
testing and certification by that office. The Secretary of State has objected to the use of
voting systems to implement cumulative voting in other CVRA cases (e.g., Santa Clarita,
Mission Viejo). No jurisdiction to date has proposed the use of a single vote system, which
is far less complicated than cumulative voting and could be implemented in the same
manner as standard district elections, with the only significant modification being a fairly
simple change to the ballot instructions provided to City voters (e.g., along the lines of
“vote for one; top two win”).
For these and other voter understanding and local resource constraint concerns, the San
Luis Obispo County Clerk Recorder has indicated that her office’s resources could not
support the City implementation of a Ranked Choice or C umulative voting election
system, even if Secretary of State approval could be obtained, which the City’s elections
experts assess as unlikely. Therefore, the County Clerk Recorder could not recommend
that the County administer the City’s elections, if the City proceeded with a ranked-choice
or a cumulative voting system, and the City would therefore need to run its own separate
elections, potentially involving a hand count of ballots. The ongoing costs and
inefficiencies of doing so would be significant.
Proposed Settlement Terms
The general outline of the negotiated settlement agreement (included in full as
Attachment A) is as follows:
1. SVREP will file a complaint alleging a CVRA violation against the City . Mr.
Shenkman has provided a draft of the complaint to counsel for the City who
has commented with suggestions and revisions which appear to be mostly
acceptable to Mr. Shenkman (Attachment B).
2. The City will answer the complaint denying liability (Attachment C).
3. The parties will then stipulate to entry of judgment which will track the terms
of the settlement and include other terms that are typical in stipulated
judgments (Attachment D).
4. The City will use a single vote process (called “Citywide Single Vote” in the
agreement) for its City Council elections in 2026 and 2028 (but not for the
office of Mayor) and in subsequent elections if Citywide Single Vote satisfies
criteria specified in the agreement as relevant under the CVRA.
5. The parties will cooperate in a voter education program concerning single
voting in advance of the 2026 City Council elections.
6. The parties agree to specified criteria to evaluate the effectiveness of
Citywide Single Vote on electoral outcomes and whether the Latinae
preferred candidate, if any, was elected in the Citywide Single Vote system
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in 2026 and/or 2028, and, if not, whether the evidence indicates the outcome
likely would have been different in District 1 of the SVREP demonstration
single-member district map (Attachment E).
7. The settlement agreement further provides that after the 2026 and the 2028
elections, SVREP and the City would share information about whether
Citywide Single Vote satisfied the criteria in that election. If the parties agree
that Citywide Single Vote has not satisfied the relevant criteria, the City
Council will have the opportunity to consider adopting single-member districts
for future elections. If the City Council determines to stick with Citywide Single
Vote, notwithstanding the parties’ agreement that Citywide Single Vote has
not satisfied the relevant criteria, SVREP may sue the City immediately
without further notice, safe-harbor tolling, or an attorneys’ fee cap, and the
City agrees not to challenge SVREP’s standing to sue as an orga nizational
plaintiff.
8. If the parties disagree whether Citywide Single Vote satisfies the relevant
criteria, the matter will be referred to a referee who will receive evidence and
briefing from the parties, make findings and recommendations, including
potential changes to the City’s electoral system, and provide a written opinion.
9. In the event the referee decides against the City, the referee’s decision will
be formally presented at a City Council meeting to consider making the
recommended changes. If the City Council chooses not to make changes,
the referee’s decision would be submitted to the Superior Court judge with
jurisdiction over the stipulated judgement. The Court’s decision on the
Referee’s determination would be binding on the parties and non-appealable.
10. The City may at any time choose to transition to district elections without
penalty, in which case it would no longer be bound by any of the above
settlement terms.
11. The City will pay plaintiff attorneys’ fees in the amounts set forth in the fiscal
impact section below (with some fees certain and some fees avoidable based
on the City’s response to conclusions of future data analyses).
PUBLIC ENGAGEMENT
The City will use its Public Engagement and Noticing Manual to develop a comprehensive
public engagement plan that will inform residents of the Citywide Single Vote update to
our at-large election system. This will primarily focus on communications from the City t o
community members to inform them of the upcoming change and will include a mix of
English and Spanish communications using paid advertisements, digital media and
channels, direct mail, signage, informational meetings and in-person outreach at various
events, partnering with key partner organizations and trusted messengers, and working
with the local media to help raise awareness of why, when and how the change is
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Item 7a
occurring and what people can expect.
During the course of negotiations toward settlement, City staff requested and received
feedback from Latinae community leaders to understand whether they were aware of
significant Latinae community interest in district elections or other electoral changes and
what measures the community leaders viewed as best serving their communities.. Those
consulted included representatives of the Diversity Coalition, SLO County
UndocuSupport, the Latino Outreach Council, Corazon Latino and other Latinae
community leaders.
None of those consulted expressed that they were receiving feedback from the
communities they serve supporting district elections. In fact, there were unanimous
concerns about the potential unintended adverse consequences of districts in disrupting
the momentum of local DEI, education, outreach and civic inclusion initiatives, as well as
the potential of districts to fragment the coalition building capacity of Latinae community
groups and voters in San Luis Obispo.
CONCURRENCE
The City Clerk and DEI Manager have been involved in ongoing settlement discu ssions
and concur with the recommendation.
ENVIRONMENTAL REVIEW
The recommended action is not a project with the potential to result in direct or indirect
physical change to the environment and, therefore, does not require environmental
review.
FISCAL IMPACT
Budgeted: Yes Budget Year: 2024-25
Funding Identified: Yes
Fiscal Analysis:
Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund $75,000 $75,000 $ $
State
Federal
Fees
Other:
Total $75,000 $75,000 $ $
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Item 7a
Costs for the current fiscal year to implement the Settlement Agreement are $75,000 for
SVREP attorneys’ fees to date. This payment is proposed to come from the fiscal year
2023-24 General Fund undesignated fund balance. The current unaudited fiscal year
2023-24 fund balance is $7,735,567. Additional commitments and recommendations for
use of this funding will be presented to the Council at the February 18, 2025, meeting with
the Mid-Year Budget Report.
Additional attorneys’ fees, some of which are avoidable by the City depending on future
data analyses and Council actions, may occur in future fiscal years, and are capped as
detailed in the fee schedule below which is included in the Settlement Agreement:
$75,000.00 SVREP Attorneys' Fees to Date
Not to Exceed
$10,000.00
Facilitation of SVREP’s Participation in Analysis Following the
2026 & 2028 City Council Elections
Not to Exceed
$200,000.00
(avoidable cost)
SVREP Attorneys’ Fees if Dispute Goes to Judicial Reference
Process
Not to Exceed
$50,000.00
(avoidable cost)
Referee Fees
No Cap If the matter goes to Court after the judicial reference procedures
Should the Council approve the Settlement Agreement, staff will also prepare a
corresponding budget request for the 2025-27 Financial Plan to implement the additional
outreach and engagement commitments included in the agreement. This will include the
tasks referenced above in the Public Engagement section of the report as well as the
commitment to conduct a Community Academy and/or other type of candidate education
and development offering annually. The total costs for this budget request is not expected
to exceed $150,000 total for the 2025-27 Financial Plan.
The City’s own costs in this matter for demographics consulting and outside counsel, for
work through the end of October 2024, are just over $216,000.
ALTERNATIVES
1. Council could elect to proceed with implementation of single member districts,
which would foreclose a subsequent legal challenge, and eliminate the need for
settlement. This alternative is not recommended due to lack of data supporting the
efficacy of that remedy and, as previously discussed, potentially adverse
consequences of districts given the City’s current demographics and dispersion data.
Mr. Shenkman would still be entitled to attorneys’ fees per statute, currently
approximately $38,000.
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Item 7a
2. Council could decline to the approve the recommended settlement and direct
staff to abandon further discussions with SVREP and decline to implement
single member districts, which would permit SVREP to sue the City to compel
district election implementation. This alternative is not recommended because it
would invite a lawsuit, would likely result in significant legal defense costs to the City,
and could expose the City to a significant attorneys’ fees award to SVREP in the event
SVREP prevailed in litigation.
ATTACHMENTS
A - Proposed Settlement Agreement
B - Revised Complaint (referenced as Exhibit A in the Settlement Agreement)
C - Draft Answer of the City (referenced as Exhibit B in the Settlement Agreement)
D - Proposed Stipulated Judgment (referenced as Exhibit C in the Settlement
Agreement)
E - SVREP demonstration single-member district map, (referenced as Exhibit D in
the settlement agreement)
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Page 34 of 59
PRE-LITIGATION SETTLEMENT AGREEMENT
AND RELEASE OF ALL CLAIMS
This Pre-Litigation Settlement Agreement and Release of all Claims (“Agreement” or “Settlement
Agreement”) is entered into this __ day of _______, 2024 (“Effective Date”) by and among the City of San
Luis Obispo (“City”), a charter city, and Southwest Voter Registration Education Project (“SVREP”), a
Texas nonprofit corporation, (City and SVREP may be referred to individually herein as “Party” and
collectively as the “Parties”), as full and complete settlement and compromise of the within matters, agree
as follows:
WHEREAS, in or about February 2023, the City received a letter dated February 17, 2023 from
attorney Kevin Shenkman of the law firm Shenkman & Hughes, PC, on behalf of SVREP and its members,
asserting that the City’s at-large election system violates the California Voting Rights Act (“CVRA”
Elections Code section 14025 et seq.) (“SVREP’s Claims”);
WHEREAS, SVREP and City have entered into a series of tolling agreements to toll the
deadlines under Elections Code section 10010 (collectively “Tolling Agreement”);
WHEREAS, the Parties have met several times since February 2023 to, among other things, review
data and discuss the relative merits of various election systems and the extent to which they might address
SVREP’s Claims; and
WHEREAS, the Parties now desire to memorialize the terms of their agreement relative to t he
City’s election system and SVREP’s Claims,
NOW, THEREFORE, in consideration of the mutual covenants, promises and conditions set forth
below, and as full and complete compromise and settlement of any and all legally applicable claims, the
Parties agree as follows:
1. CVRA Litigation
SVREP shall, promptly upon full execution of this Agreement, file a lawsuit against City in the
San Luis Obispo Superior Court, alleging a single cause of action for violation of the CVRA
(“CVRA Action”). City will not contest SVREP’s standing to file the lawsuit and waives any
affirmative defense based on standing. The complaint shall be substantially in the form attached
hereto as Exhibit A. Within five court days of filing the CVRA Action, City shall file an answer
generally denying the allegations in the CVRA Action. The City’s answer shall be substantially in
the form attached hereto as Exhibit B. Within five court days of filing the City’s Answer, SVREP
shall file the Stipulation for Entry Judgment and Proposed Judgment, attached as Exhibit C, to
affect the terms of this Agreement. In the event the San Luis Obispo Superior Court refuses to
enter judgment in substantially the form attached as Exhibit C, this Agreement shall be null and
void and the Parties shall meet and confer in good faith regarding the CVRA action.
2. Citywide Single-vote Voting and Education Period.
a. City’s Electoral System. Subject to change in accordance with this Agreement:
the City may maintain an electoral system in which four City Council members are elected at-large
and the office of mayor is directly elected by the voters; City Council members are elected every
two years to staggered four-year terms, with term limits of two consecutive full terms; and the
Mayor is elected every two years to a two-year term, with term limits of four consecutive full terms.
City may at any time implement district-based elections, as that phrase is defined in the CVRA, for
Page 35 of 59
the election of its four city council members in accordance with Section 5 of this Agreement and
maintain an office of Mayor directly-elected by all the voters in the City.
b. Citywide Single-vote Voting for City Elections. The Parties agree that City shall
conduct its 2026 elections for its City Council members and all City Council elections thereafter
utilizing Citywide Single-vote voting – a system in which all voters citywide cast a single vote,
regardless of the number of seats to be elected, and the two candidates receiving the most votes are
elected. Unless the City’s method of election is modified pursuant to this Agreement prior to an
election, the City shall conduct that corresponding election for its city council utilizing Citywide
Single-vote voting.
c. Cooperation in Outreach, Education Efforts, and Candidate Development. The
Parties shall reasonably cooperate with one another between the Effective Date and November
2026 in connection with efforts to educate voters regarding the Citywide Single-vote voting system,
as well as efforts to encourage voter registration and turnout directed at historically marginalized
communities within the City. SVREP shall reasonably assist City upon City’s request, by providing
its know-how in connection with efforts to educate voters and encourage voter registration and
turnout among historically marginalized communities. City will agree to conduct a Community
Academy bi-annually (every other year) and will provide another candidate education and
development offering bi-annually in years alternating with Community Academy. In consultation
with SVREP, the City will provide reasonable support for participants (e.g. transportation,
childcare, meals) to mitigate barriers to participation.
d. In the event the County Registrar of Voters declines for any reason to conduct the
City Council elections using Citywide Single-vote voting consolidated with the statewide election,
the Parties shall meet and confer in good faith regarding the CVRA Action.
3. Meet and Confer and Dispute Resolution
a. Meet-and-Confer. Within ninety (90) days following the certification of the 2026
and 2028 City Council elections, if those elections are conducted utilizing Citywide Single-vote
voting, the Parties shall meet and confer concerning the corresponding election and results.
Specifically, the parties will work cooperatively to determine whether the election(s) demonstrated
that Citywide Single-vote voting as implemented by City in the previous election(s) positively
impacted the facts (set forth below), which the parties agree are relevant to analysis of a CVRA
violation as alleged in the CVRA Action.
b. Relevant Facts. Citywide Single-vote voting shall be deemed to have positively
impacted the relevant facts if the Latino-preferred candidate, if any, was elected in the
corresponding election(s). If the Latino-preferred candidate was not elected in both of the elections,
the Parties shall also consider as a relevant fact under the totality of the circumstances whether the
Latino-preferred candidate would have been elected in those elections in District 1 of the SVREP
demonstration single-member district map attached hereto as Exhibit D. The Parties shall endeavor
to openly exchange information, data and analyses in the course of their meet and confer process,
subject to protections as confidential settlement discussions from third party disclosure and
admission as evidence in a later action against the City. Following the 2028 election, the City will
bring forward for consideration at a public meeting an agenda item regarding implementation of
by-district elections, if the relevant facts demonstrate that the Latino-preferred candidate was not
elected using Citywide Single-vote voting in the 2026 and 2028 elections and that the Latino-
preferred candidate would have been elected in those elections in District 1 of the SVREP
demonstration single-member district map, attached hereto as Exhibit D. In the event the City
Page 36 of 59
Council declines to proceed with implementation of district-based elections for City Council seats
based on the relevant facts set forth herein, then SVREP may initiate CVRA litigation against the
City to compel the City to implement district-based elections without the need for further demand
by SVREP and without regard to the safe harbor provisions of the Elections Code, provided that
SVREP shall only be entitled to recover attorneys’ fees, in addition to those provided under this
Agreement, that are incurred on and after any date on which the City Council, after the public
meeting contemplated herein, declines to implement district-based elections as contemplated
herein.
c. Initiation of Dispute Resolution. If the Parties are not able to agree, following the
2028 elections, whether the Citywide Single-vote voting implemented by City in the 2026 and
2028 elections is positively impacting the relevant facts, as set forth in subsection 3(b), the Parties
shall promptly refer their disagreement to be decided through a judicial reference. The referee
shall issue a written decision. The parties shall meet and confer in good faith regarding judicial
reference procedures.
d. Selection of Referee. The Parties have selected Bernard N. Grofman a professor
at the University of California, Irvine, to serve as Referee. In the event, for whatever reason,
Professor Grofman is unavailable or unwilling to serve as the Referee, then the Parties select
Nathaniel Persily, a professor at Stanford Law School, to serve as Referee. In the event, for
whatever reason, Professor Persily is unavailable or unwilling to serve as the Referee, then the
Parties select Christian Grose to serve as Referee. In the event, for whatever reason, Christiain
Grose is unavailable or unwilling to serve as the Referee, then the Parties shall meet to identify a
suitable Referee by mutual consent. If the Parties are unable to reach mutual consent, the California
Superior Court (County of San Luis Obispo) shall appoint the Referee.
e. Cost of Referee. The cost of the Referee shall be borne by the City. The fees and
expenses of the Referee shall not exceed $50,000.00.
4. Attorneys’ Fees and Expenses.
a. City shall pay SVREP’s reasonable attorneys’ fees and expenses for work up to the
entry of the judgment contemplated in Section 1 above, consistent with Elections Code
section 14030 and/or Code of Civil Procedure section 1021.5, in the amount of
$75,000.00. This amount is in full satisfaction of SVREP’s claims for attorneys’ fees,
costs, and expenses, including expert fees and expenses, up to the entry of judgment
contemplated in Section 1, above.
b. City shall also pay SVREP’s attorneys’ fees and expenses associated with monitoring
and evaluating the 2026 and 2028 elections and the effectiveness of Citywide Single-
vote voting in those elections up to a maximum of $10,000.00 for each election.
c. In the event of a dispute pursuant to Section 3 of this Agreement and the Referee
decides that SVREP is the prevailing party in such dispute, City shall also pay SVREP
its reasonable attorneys’ fees and expenses associated with the Dispute Resolution in
an amount not to exceed $200,000.00, as well as any attorneys’ fees and expenses
incurred in determining the amount of such reasonable attorneys’ fees and expenses, if
contested by the City. SVREP shall provide documentation of its reasonable attorneys’
fees and expenses. In the event the Referee recommends remedial action, but the City
Council declines to voluntarily implement that remedial action, thus necessitating
presentation of the Referee’s recommendation to the Superior Court, the cap on fees
Page 37 of 59
and expenses expressed in this subparagraph shall apply only to those fees incurred
up to the date of the Council action declining to implement the Referee’s
recommendation, and this agreement shall not limit any subsequent action by SVREP
to recover all reasonable attorneys’ fees, as determined by the court, incurred by
SVREP from the date of the Council action through the date of conclusion of the
judicial reference proceedings before the superior court.
d. Payment of the attorneys’ fees and costs shall be made in the form of a check or wire
transfer to Shenkman & Hughes PC at 28905 Wight Rd., Malibu, CA 90265 no later
than 30 days following the corresponding agreement on the amount of attorneys’ fees
and expenses or Referee determination of that amount.
e. The payments provided for in this Agreement do not extinguish SVREP’s attorneys’
right to claim attorneys’ fees and expenses pursuant to Elections Code §10010(f) in the
event the City adopts a by-district election system in response to a notice pursuant to
Elections Code § 10010(e) from others who are not parties to this Agreement. It is the
intent of the parties that the attorneys for SVREP will be deemed first in right under
Elections Code § 10010(f)(2) to the fullest extent permitted by law.
f. Other than as set forth above, the Parties shall bear their own attorneys’ fees and
expenses relating to this Agreement and the subject matter thereof.
5. Notwithstanding anything to the contrary herein, City may at any time implement district-
based elections, as that phrase is defined in the CVRA, for the election of its city council members and
maintain a directly elected office of mayor. In the event that City chooses to implement district-based
elections, rather than Citywide Single-vote voting, in either the 2026 or 2028 elections, or both, the
provisions of Sections 2 and 3, above, with regard to that election, and the provisions in Section 4
concerning fees and costs associated with monitoring and evaluating the 2026 and/or 2028 elections, shall
be inapplicable.
6. The Parties acknowledge and agree that any and all matters, claims and causes of action
arising on or before the date of the execution of this Settlement Agreement which any Party has, has had,
may have or may have had against the other Parties, including but not limi ted to SVREP’s Claims against
the City, are hereby fully compromised and settled except to the extent specifically identified in this
Agreement.
7. Each Party waives and releases the other Parties from any and all rights, claims, causes of
action, demands, liabilities, obligations, contracts, damages, penalties, complaints, charges, grievances, and
duties, whether legal, equitable or contractual, asserted or not asserted, known or unknown, suspected to
exist or not suspected to exist, which that Party now has, may have, claims to have or may claim to have
against the other Parties arising prior to or on the date of this Settlement Agreement.
8. Each Party has read and understands the following statutory language of Section 1542 of
the California Civil Code:
“A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE
CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER
FAVOR AT THE TIME OF EXECUTING THE RELEASE WHICH, IF KNOWN
BY HIM OR HER, MUST HAVE MATERIALLY AFFECTED HIS OR HER
SETTLEMENT WITH THE DEBTOR.”
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Having been so apprised, the Party elects to waive the benefits of Section 1542, and further elects
to and does assume all risks for any and all claims, whether known or unknown, suspected or not suspected,
arising from the subject matter of this Settlement Agreement, including but not limited to the matters
released herein, and knowingly and voluntarily releases the other Parties from any and all liability and
claims arising out of such matters.
9. Except as explicitly stated herein, including in Sections 3(e) and 4, the Parties shall bear
all of their own costs, expenses and attorneys’ fees incurred in connection with the CVRA Action, the
negotiation of this settlement agreement, and the completion of the Meet and Confer and Referee process
set forth in Section 3 of this Agreement and as agreed in the parties’ meet and confer regarding judicial
reference procedures.
10. No part of this Settlement Agreement may be amended, modified or waived in any way
unless such amendment, modification or waiver is set forth in a later writing signed by all the Parties. A
modification, amendment or waiver of any one provision of this Settlement Agreement shall not be deemed
to be a modification, amendment or waiver of any other provision of this Settlement Agreement.
11. The provisions of this Settlement Agreement shall be binding upon and inure to the benefit
of each of the Parties and their respective successors and assigns.
12. The Parties acknowledge and agree that this Settlement Agreement is a complete
expression of all of their agreements and understandings concerning the subject matter hereof, and that any
prior or contemporaneous agreements, understandings or representations of the parties, whether express or
implied, are no longer of any force and effect.
13. If a court of competent jurisdiction finally holds that any provision of this Settlement
Agreement is invalid, illegal, or unenforceable, that holding shall not affect the validity of the other
provisions of this Settlement Agreement, which shall remain in full force and effect, and this Settlement
Agreement shall be construed as if the offending provision(s) had not been contained herein.
14. The laws of the State of California, without giving effect to its conflict of law provisions,
shall govern any dispute, claim, action or proceeding relating to or arising out of this Agreement. Venue
shall be in San Luis Obispo County.
15. This Settlement Agreement may be executed in counterparts and each counterpart, when
executed, shall have the efficacy of a second original. Photographic or facsimile copies of any such signed
counterparts may be used in lieu of the original for any purpose.
16. Electronic Signing: Each Party agrees that the other Parties may use an electronic signature
technology, e.g., DocuSign, to expedite the execution of this Agreement.
Dated: City of San Luis Obispo
By _________________________________________
Whitney McDonald,
City Manager, City of San Luis Obispo
Page 39 of 59
Dated: Southwest Voter Registration Education Project
By ________________________________________
Lydia Camarillo
President Southwest Voter Registration Education
Project
APPROVED AS TO FORM:
Dated: Nielsen Merksamer Parrinello Gross & Leoni, LLP
By _________________________________________
Marguerite Mary Leoni
Special Attorneys for City of San Luis Obispo
Dated:
_____________________________________________
J. Christine Dietrick
City Attorney, City of San Luis Obispo
Dated: Shenkman & Hughes
By _________________________________________
Kevin I. Shenkman
Attorneys for Southwest Voter Registration Education
Project
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COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
Kevin I. Shenkman (SBN 223315) Mary R. Hughes (SBN 222622) Andrea A. Alarcon (SBN 319536) SHENKMAN & HUGHES PC 28905 Wight Road Malibu, California 90265 Telephone: (310) 457-0970 Attorneys for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN LUIS OBISPO
SOUTHWEST VOTER REGISTRATION EDUCATION PROJECT; Plaintiff, v. CITY OF SAN LUIS OBISPO, CALIFORNIA; and DOES 1-100, inclusive, Defendants.
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Case No.: COMPLAINT FOR VIOLATION OF THE CALIFORNIA VOTING RIGHTS ACT OF 2001
COMES NOW Plaintiff Southwest Voter Registration Education Project (hereinafter
“SVREP” or “Plaintiff”), and allege as follows:
GENERAL ALLEGATIONS
1. This action is brought by Plaintiff for injunctive and declaratory relief against
the City of San Luis Obispo, California, for its violation of the California Voting Rights Act
of 2001 (hereinafter the "CVRA"), Cal. Elec. Code §§ 14025, et seq. Plaintiff alleges that the
City of San Luis Obispo’s implementation of at-large elections, in which all city voters may
cast as many votes as there are open seats up for election on the City Council and an
additional vote for the separately elected Mayor, has resulted in vote dilution for Latino
residents and has denied them effective political participation in elections to the San Luis
Obispo City Council. Specifically, Plaintiffs allege that the City of San Luis Obispo’ at-large
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COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
method of election for electing members to its City Council prevents Latino residents from
electing candidates of their choice or influencing the outcome of San Luis Obispo’s City
Council elections.
2. Plaintiff alleges that, despite a Latino population of approximately 19% in the
City of San Luis Obispo, according to the 2020 Census, the candidates preferred by Latino
voters lose in elections within San Luis Obispo and this consistent pattern reveals a lack of
access to the political process.
3. Plaintiff brings this action to enjoin the City of San Luis Obispo’s continued
abridgment of its residents’ voting rights. Plaintiff seeks a declaration from this Court that
the City of San Luis Obispo’s at-large elections, for its city council, violates the CVRA.
Plaintiff seeks injunctive relief enjoining the City of San Luis Obispo from further imposing
or applying an at-large method of election. Plaintiffs do not allege at this time, and are not
required to prove, the City of San Luis Obispo intended to discriminate through the use of its
at-large method of election. Further, Plaintiff seeks injunctive relief requiring the City of San
Luis Obispo to implement district-based elections, or other alternative relief, as discussed in
Pico Neighborhood Ass'n v. City of Santa Monica (2023) 15 Cal. 5th 292.
4. Through correspondence to the City of San Luis Obispo sent in February 2023
via certified mail pursuant to section 10010 of the Elections Code, Plaintiff, through the
undersigned counsel, asserted that the City’s method of conducting elections may violate the
California Voting Rights Act of 2001.
PARTIES
5. SVREP, founded in 1974, is the largest and oldest non-partisan Latino voter
participation organization in the United States. SVREP was founded to ensure the voting
rights of minorities in the Southwest United States, and continues that mission today, now
operating in various states, including California. Over the course of the last few decades,
SVREP has been at the forefront of major social and political gains for Latinos in the U.S.
and throughout Latin America. While its primary mission is voter registration and education,
SVREP is also involved in ensuring fair elections, community organizing, and education,
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COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
accountability and training of community leaders and elected officials. In California, SVREP
has been in the forefront of efforts to enforce the California Voting Rights Act.
6. At all times herein mentioned, Defendant City of San Luis Obispo, California
(hereinafter "San Luis Obispo") is and has been a charter city subject to the provisions of the
CVRA.
7. Plaintiff is unaware of the true names and capacities, whether individual,
corporate, associate, or otherwise, of defendants sued herein as Does 1 through 100,
inclusive, and therefore, sue said defendants by such fictitious names and will ask leave of
court to amend this complaint to show their true names and capacities when the same have
been ascertained. Plaintiff is informed and believes and thereon alleges that defendants Does
1 through 100, inclusive, are responsible on the facts and theories herein alleged.
8. Does 1 through 100, inclusive, are Defendants that have caused San Luis
Obispo to violate the CVRA, failed to prevent San Luis Obispo’ violation of the CVRA, or
are otherwise responsible for the acts and omissions alleged herein.
9. Plaintiff is informed and believes and thereon alleges that Defendants and each
of them are in some manner legally responsible for the acts and omissions alleged herein, and
actually and proximately caused and contributed to the various injuries and damages referred
to herein.
10. Plaintiff is informed and believes and thereon alleges that at all times herein
mentioned each of the Defendants were the agent, partner, predecessor in interest, successor
in interest, and/or employee of one or more of the other Defendants, and were at all times
herein mentioned acting within the course and scope of such agency and/or employment.
JURIDICTION AND VENUE
11. All parties hereto are within the unlimited jurisdiction of this Court. The
unlawful acts complained of occurred in San Luis Obispo County. Venue in this Court is
proper.
FACTUAL ALLEGATIONS
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COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
12. The City of San Luis Obispo contains approximately 47,400 persons, of which
approximately 19% are Latino, based upon the 2020 United States Census.
13. The City of San Luis Obispo is governed by a city council of five members –
four members who serve four-year terms and a directly elected mayor who serves a two-year
term. The San Luis Obispo City Council serves as the governmental body responsible for the
policy and budgetary direction, and appointment and oversight of the City Manager
responsible for operations, of the City of San Luis Obispo.
14. The San Luis Obispo City Council members are elected pursuant to an “at-large
method of election,” as that term is defined by Section 14026 of the Election Code.
15. Vacancies to the City Council are elected on a staggered basis; as a result, every
two years the city electorate elects two council members as well as the mayor.
16. Elections conducted within the City of San Luis Obispo are characterized by
racially polarized voting. Racially polarized voting occurs when members of a protected
class as defined by the CVRA, Cal. Elec. Coed § 14025(d), vote for candidates and electoral
choices that are different from the rest of the electorate. Racially polarized voting exists
within the City of San Luis Obispo because there is a difference between the choice of
candidates or other electoral choices that are preferred by Latino voters and the choice of
candidates or other electoral choices that are preferred by voters in the rest of the electorate,
with the result being that Latino-preferred candidates usually lose.
17. Racially polarized voting is legally significant in San Luis Obispo City Council
elections because it dilutes the opportunity of Latino voters to elect candidates of their choice
or influence the outcome of those elections.
18. Patterns of racially polarized voting have the effect of impeding opportunities
for Latino voters to elect candidates of their choice to the at-large city council positions in the
City of San Luis Obispo or influence the outcome of those elections, where the non-Latino
electorate dominates elections. For several years, Latino voters have been harmed by racially
polarized voting.
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COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
19. The at-large multiple-vote method of election and repeated racially polarized
voting has caused Latino vote dilution within the City of San Luis Obispo. Where Latinos
and the rest of the electorate express different preferences on candidates and other electoral
choices, non-Latinos by virtue of their overall numerical majority among voters, defeat the
preferences of Latino voters.
20. The obstacles posed by at-large multiple-vote elections in the City of San Luis
Obispo, together with racially polarized voting, impair the abilit y of people of certain races,
color or language minority groups, such as Latino voters, to elect candidates of their choice or
to influence the outcome of elections conducted in the City of San Luis Obispo.
21. An alternative method of election, such as district-based elections, or an
alternative method of election as discussed in Pico Neighborhood Ass’n v. City of Santa
Monica (2023) 15 Cal.5th 292, exists that will provide an opportunity for the members of the
protected classes as defined by the CVRA to elect candidates of their choice or to influence
the outcome of the San Luis Obispo City Council elections.
FIRST CAUSE OF ACTION
(Violation of California Voting Rights Act of 2001)
(Against All Defendants)
22. Plaintiff incorporates by this reference paragraphs 1 through 26 as though fully
set forth herein.
23. Defendant City of San Luis Obispo is a political subdivision within the State of
California.
24. Defendant City of San Luis Obispo has employed an at-large method of
election, where voters of its entire jurisdiction elect all members to its City Council.
25. Racially polarized voting has occurred, and continues to occur, in elections for
members of the City Council for the City of San Luis Obispo and/or in elections
incorporating other electoral choices by voters of the City of San Luis Obispo, California.
Absent remedial measures ordered by this Court, racially polarized voting will continue to
plague elections held in San Luis Obispo. As a result, the City of San Luis Obispo’ at-large
Page 45 of 59
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_____________________________________________________________________________
COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
method of election is imposed in a manner that impairs the ability of protected classes as
defined by the CVRA to elect candidates of their choice or influence the outcome of
elections.
26. An alternative method of election, such as district-based elections, or an
alternative method of election as discussed in Pico Neighborhood Ass’n v. City of Santa
Monica exists that will provide an opportunity for the members of a protected class as defined
by the CVRA to elect candidates of their choice or to influence the outcome of the San Luis
Obispo City Council elections.
27. An actual controversy has arisen and now exists between the parties relating to
the legal rights and duties of Plaintiff and Defendants, for which Plaintiff desires a
declaration of rights.
28. Defendants’ wrongful conduct has caused and, unless enjoined by this Court,
will continue to cause, immediate and irreparable injury to Plaintiff, and all residents of the
City of San Luis Obispo.
29. Plaintiff and the residents of the City of San Luis Obispo have no adequate
remedy at law for the injuries they currently suffer and will otherwise continue to suffer.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as
follows:
1. For a decree that the City of San Luis Obispo’s at-large method of election for
all or any portion of the City Council violates the California Voting Rights Act of 2001;
2. For preliminary and permanent injunctive relief enjoining the City of San Luis
Obispo from imposing or applying an at-large method of election;
3. For injunctive relief mandating the City of San Luis Obispo to implement
district-based elections, as defined by the California Voting Rights Act of 2001, employing a
district map tailored to remedy Defendant’s violation of the California Voting Rights Act of
2001, or other election system tailored to eliminate the vote dilution of the City of San Luis
Obispo’s at-large multiple-vote elections;
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_____________________________________________________________________________
COMPLAINT
EXHIBIT A TO SETTLEMENT AGREEMENT
4. For injunctive relief mandating the prompt election of city council members
through district-based elections, or another election method tailored to remedy Defendant’s
violation of the California Voting Rights Act of 2001,
5. Other relief tailored to remedy the City of San Luis Obispo’s violation of the
California Voting Rights Act of 2001;
6. For an award of Plaintiff' attorneys’ fees, costs, litigation expenses and
prejudgment interest pursuant to Elec. Code § 14030 and other applicable law; and
7. For such further relief as the Court deems just and proper.
Respectfully submitted: DATED: ________, 2024 SHENKMAN & HUGHES PC By: /s/Kevin Shenkman________________________ Kevin Shenkman Attorneys for Plaintiff
Page 47 of 59
Page 48 of 59
________________________________________________________________________________
DEFENDANT CITY OF SAN LUIS OBISPO’S CASE NO. _______________
ANSWER TO UNVERIFIED COMPLAINT
EXHIBIT B TO SETTLEMENT AGREEMENT Page i
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN LUIS OBISPO
SOUTHWEST VOTER REGISTRATION
EDUCATION PROJECT,
Plaintiff,
vs.
CITY OF SAN LUIS OBISPO, CALIFORNIA;
and DOES 1-100, inclusive,
Defendants.
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Case No.
ANSWER OF DEFENDANT CITY
OF SAN LUIS OBISPO TO
UNVERIFIED COMPLAINT FOR
VIOLATION OF THE CALIFORNIA
VOTING RIGHTS ACT OF 2001
JUDGE:
DEPARTMENT:
ACTION FILED:
[CITY OF SLO CAPTION]
NIELSEN MERKSAMER
PARRINELLO GROSS & LEONI LLP
Marguerite Mary Leoni (S.B. No. 101696)
Christopher E. Skinnell (S.B. No. 227093)
2350 Kerner Boulevard, Suite 250
San Rafael, California 94901
Telephone: (415) 389-6800
Facsimile: (415) 388-6874
Email: mleoni@nmgovlaw.com
Email: cskinnell@nmgovlaw.com
Attorneys for Defendant
CITY OF SAN LUIS OBISPO
EXEMPT FROM FILING FEES
[GOV’T CODE § 6103]
Page 49 of 59
________________________________________________________________________________
DEFENDANT CITY OF SAN LUIS OBISPO’S CASE NO. _______________
ANSWER TO UNVERIFIED COMPLAINT
EXHIBIT B TO SETTLEMENT AGREEMENT Page 1
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Defendant CITY OF SAN LUIS OBISPO (hereinafter “Defendant”) answers the unverified
complaint of plaintiff SOUTHWEST VOTER REGISTRATION EDUCATION PROJECT as
hereinafter set forth.
I. GENERAL DENIAL
1. Pursuant to Section 431.30(d) of the California Code of Civil Procedure, Defendant
generally and specifically denies each and every allegation, statement, matter, and thing set forth in
and alleged in the unverified complaint, and specifically denies that Defendant has violated the
California Voting Rights Act of 2001 (California Elections Code § 14025 et seq., hereinafter the
“Act”) and denies that Plaintiffs are entitled to the relief prayed for or any relief whatsoever against
Defendant.
II. AFFIRMATIVE DEFENSES
2. For Defendant’s separate and additional affirmative defenses to the cause of action
alleged in the unverified complaint, and without admitting that Defendant has the burden of proof
on any of these defenses, Defendant alleges as follows:
FIRST AFFIRMATIVE DEFENSE
(Failure to State a Cause of Action, Elec. Code § 14027)
3. The cause of action contained in the Complaint fails to allege facts demonstrating
dilution of the ability of Latino voters to elect chosen candidates or influence the outcome of
elections.
SECOND AFFIRMATIVE DEFENSE
(Failure to State a Cause of Action, Elec. Code § 14028)
4. The cause of action contained in the Complaint fails to allege facts demonstrating
racially polarized voting sufficient to state a cause of action against Defendant.
THIRD AFFIRMATIVE DEFENSE
(Failure to State a Cause of Action, Elec. Code § 14028)
5. The cause of action contained in the Complaint fails to allege facts demonstrating
Latino-preferred candidates, including candidates who are themselves Latino, fail to win election
Page 50 of 59
________________________________________________________________________________
DEFENDANT CITY OF SAN LUIS OBISPO’S CASE NO. _______________
ANSWER TO UNVERIFIED COMPLAINT
EXHIBIT B TO SETTLEMENT AGREEMENT Page 2
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to the City Council.
FOURTH AFFIRMATIVE DEFENSE
(As-Applied Violation of the Fourteenth Amendment to the United States Constitution and
Article I, § 7, of the California Constitution)
6. The Act is unconstitutional as applied to Defendant pursuant to the provisions of Section 1
of the Fourteenth Amendment to the United States Constitution, and to the provisions of Section 7
of Article I of the California Constitution.
PRAYER
WHEREFORE, Defendant prays for judgment that:
1. That Plaintiff takes nothing by its Complaint;
2. For entry of Judgment against Plaintiff and in favor of Defendant; and
3. That Defendant be awarded its costs of suit and attorneys’ fees; and
4. That the Court order such further relief to Defendant as deemed just and proper.
Dated: November ____, 2024 CITY SAN LUIS OBISPO
By: _______________________
Christine A. Dietrick
City Attorney
NIELSEN MERKSAMER
PARRINELLO GROSS & LEONI LLP
By: ________________________
Marguerite Mary Leoni
Christopher E. Skinnell
Attorneys for Defendant
City of San Luis Obispo
Page 51 of 59
Page 52 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN LUIS OBISPO
SOUTHWEST VOTER REGISTRATION
EDUCATION PROJECT,
Plaintiff,
vs.
CITY OF SAN LUIS OBISPO,
CALIFORNIA; and DOES 1-100, inclusive,
Defendants.
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Case No.
STIPULATED JUDGMENT
JUDGE:
DEPARTMENT:
ACTION FILED:
Plaintiff SOUTHWEST VOTER REGISTRATION EDUCATION PROJECT and
Defendant CITY OF SAN LUIS OBISPO, CALIFORNIA, a public entity (“Defendant”), having
stipulated to all terms and conditions set forth herein, and having requested the Court to make and
enter a Judgment consistent with said stipulation, the Court renders its judgment as follows:
Page 53 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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1. Citywide Single-vote Voting and Education Period.
a. City’s Electoral System. Subject to change a set forth below: the City may maintain
an electoral system in which four City Council members are elected at-large and the office
of mayor is directly elected by the voters; City Council members are elected every two years
to staggered four-year terms, with term limits of two consecutive full terms; and the Mayor
is elected every two years to a two-year term, with term limits of four consecutive full
terms. City may at any time implement district-based elections, as that phrase is defined in
the CVRA, for the election of its four city council members in accordance with Section 4 of
this Stipulated Judgment and maintain an office of Mayor directly-elected by all the voters
in the City.
b. Citywide Single-vote Voting for City Elections. The City shall conduct its 2026
elections for its City Council members and all City Council elections thereafter utilizing
Citywide Single-vote voting – a system in which all voters citywide cast a single vote,
regardless of the number of seats to be elected, and the two candidates receiving the most
votes are elected. Unless the City’s method of election is modified pursuant to this
Stipulated Judgment prior to an election, the City shall conduct that corresponding election
for its city council utilizing Citywide Single-vote voting.
c. Cooperation in Outreach, Education Efforts, and Candidate Development. The
Parties shall reasonably cooperate with one another between the Effective Date and
November 2026 in connection with efforts to educate voters regarding the Citywide Single-
vote voting system, as well as efforts to encourage voter registration and turnout directed at
historically marginalized communities within the City. SVREP shall reasonably assist City
upon City’s request, by providing its know-how in connection with efforts to educate voters
and encourage voter registration and turnout among historically marginalized communities.
City will conduct a Community Academy bi-annually (once every other year) and will
provide another candidate education and development offering bi-annually in years
alternating with Community Academy. In consultation with SVREP, the City will provide
Page 54 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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reasonable support for participants (e.g. transportation, childcare, meals) to mitigate barriers
to participation.
d. In the event the County Registrar of Voters declines for any reason to conduct the
City Council elections using Citywide Single-vote voting consolidated with the statewide
election, the Parties shall meet and confer in good faith regarding the CVRA Action.
2. Meet and Confer and Dispute Resolution.
a. Meet-and-Confer. Within ninety (90) days following the certification of the 2026
and 2028 City Council elections, if those elections are conducted utilizing Citywide Single-
vote voting, the Parties shall meet and confer concerning the corresponding election and
results. Specifically, the parties will work cooperatively to determine whether the election(s)
demonstrated that Citywide Single-vote voting as implemented by City in the previous
election(s) positively impacted the facts (set forth below), which are relevant to analysis of a
CVRA violation as alleged in the CVRA Action.
b. Relevant Facts. Citywide Single-vote voting shall be deemed to have positively
impacted the relevant facts if the Latino-preferred candidate, if any, was elected in the
corresponding election(s). If the Latino-preferred candidate, if any, was not elected in both
of the elections, the Parties shall also consider as a relevant fact under the totality of the
circumstances whether the Latino-preferred candidate would have been elected in those
elections in District 1 of the SVREP demonstration single-member district map, attached as
Exhibit D to the Pre-Litigation Settlement Agreement And Release Of All Claims between
the Parties. The Parties shall endeavor to openly exchange information, data and analyses in
the course of their meet and confer process, subject to protections as confidential settlement
discussions from third party disclosure and admission as evidence in a later action against
the City. Following the 2028 election, the City will bring forward for consideration at a
public meeting an agenda item regarding implementation of by-district elections, if the
relevant facts demonstrate that the Latino-preferred candidate was not elected using
Citywide Single-vote voting in the 2026 and 2028 elections and that the Latino-preferred
Page 55 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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candidate would have been elected in those elections in District 1 of the SVREP
demonstration single-member district map, attached hereto as Exhibit D. In the event the
City Council declines to proceed with implementation of district-based elections for City
Council seats based on the relevant facts set forth herein, then SVREP may initiate CVRA
litigation against the City to compel the City to implement district-based elections without
the need for further demand by SVREP and without regard to the safe harbor provisions of
the Elections Code, provided that SVREP shall only be entitled to recover attorneys’ fees, in
addition to those provided under this Stipulated Judgment, that are incurred on and after any
date on which the City Council, after the public meeting contemplated herein, declines to
implement district-based elections as contemplated herein.
c. Initiation of Dispute Resolution. If the Parties are not able to agree, following the
2028 elections, whether the Citywide Single-vote voting implemented by City in the 2026
and 2028 elections is positively impacting the relevant facts, as set forth in subsection 2(b),
above, the Parties shall promptly refer their disagreement to be decided through a judicial
reference. The referee shall issue a written decision. The parties shall meet and confer in
good faith regarding judicial reference procedures.
d. Selection of Referee. The Parties have selected Bernard N. Grofman a professor at
the University of California, Irvine, to serve as Referee. In the event, for whatever reason,
Professor Grofman is unavailable or unwilling to serve as the Referee, then the Parties
select Nathaniel Persily, a professor at Stanford Law School, to serve as Referee. In the
event, for whatever reason, Professor Persily is unavailable or unwilling to serve as the
Referee, then the Parties select Christian Grose to serve as Referee. In the event, for
whatever reason, Christiain Grose is unavailable or unwilling to serve as the Referee, then
the Parties shall meet to identify a suitable Referee by mutual consent. If the Parties are
unable to reach mutual consent, the court shall appoint the Referee.
e. Cost of Referee. The cost of the Referee shall be borne by the City. The fees and
expenses of the Referee shall not exceed $50,000.00.
Page 56 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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3. Attorneys’ Fees and Expenses.
a. City shall pay SVREP’s reasonable attorneys’ fees and expenses for work up to t he
entry of this stipulated Judgment consistent with Elections Code section 14030 and/or Code
of Civil Procedure section 1021.5, in the amount of $75,000.00. This amount is in full
satisfaction of SVREP’s claims for attorneys’ fees, costs, and expenses, including expert
fees and expenses, up to the entry of this Stipulated Judgment.
b. City shall also pay SVREP’s attorneys’ fees and expenses associated with
monitoring and evaluating the 2026 and 2028 elections and the effectiveness of Citywide
Single-vote voting in those elections up to a maximum of $10,000.00 for each election.
c. In the event of a dispute pursuant to Section 2, above, and the Referee decides that
SVREP is the prevailing party in such dispute, City shall also pay SVREP its reasonable
attorneys’ fees and expenses associated with the Dispute Resolution in an amount not to
exceed $200,000.00, as well as any attorneys’ fees and expenses incurred in determining the
amount of such reasonable attorneys’ fees and expenses, if contested by the City. SVREP
shall provide documentation of its reasonable attorneys’ fees and expenses. In the event the
Referee recommends remedial action, but the City Council declines to voluntarily
implement that remedial action, thus necessitating presentation of the Referee’s
recommendation to the Superior Court, the cap on fees and expenses expressed in this
subparagraph shall apply only to those fees incurred up to the date of the Council action
declining to implement the Referee’s recommendation, and this judgment shall not limit any
subsequent action by SVREP to recover all reasonable attorneys’ fees, as determined by the
court, incurred by SVREP from the date of the Council action through the date of
conclusion of the judicial reference proceedings before the superior court.
d. Payment of the attorneys’ fees and costs shall be made in the form of a check or wire
transfer to Shenkman & Hughes PC at 28905 Wight Rd., Malibu, CA 90265 no later than
30 days following the corresponding agreement on the amount of attorneys’ fees and
expenses or Referee determination of that amount.
Page 57 of 59
STIPULATED JUDGMENT CASE NO. ___________________
EXHIBIT C TO SETTLEMENT AGREEMENT
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e. Other than as set forth above, the Parties shall bear their own attorneys’ fees and
expenses relating to this action and the subject matter thereof.
4. District-based Elections.
Notwithstanding anything to the contrary herein, City may at any time implement district-
based elections, as that phrase is defined in the CVRA, for the election of its city council members
and maintain a directly elected office of mayor. In the event that City chooses to implement
district-based elections, rather than Citywide Single-vote voting, in either the 2026 or 2028
elections, or both, the provisions of Sections 1 and 2, above, with regard to that election, and the
provisions in Section 3 concerning fees and costs associated with monitoring and evaluating the
2026 and/or 2028 elections, shall be inapplicable.
5. The Court shall retain jurisdiction to enforce the terms of this Stipulated Judgment and the
Settlement Agreement pursuant to Code of Civil Procedure Section 664.6.
Dated: ____________ _____________________________________
HON. ________________________________
JUDGE, SUPERIOR COURT OF THE
STATE OF CALIFORNIA IN AND FOR
THE COUNTY OF ORANGE
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Old Windmill
F e e d M ill R d
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Fernandez Ln
Je
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f
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D
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Santa Clara St
Mountain-View
Magnolia
Du
n
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L
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Ironbark St
Mira Sol Dr
Larkspur St
F
l
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Wavertree St
P
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D
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Ja
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D
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Orange Dr
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Branch St
Stafford St
Redwood
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M o ntalb a n S t
Pis m o StPacific StPalmmill Aly
W aln ut S t
Maple
Alrita St
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Mitchell Dr
Margarita Ave
C y c l a m e n C t
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Kentucky Aly
Pine
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Vis del Lago
M o ntere y S t
C h urc h St
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C o r a l S t
Lincoln St
Aralia Ct
Donegal Dr
Funston Ave
C
arpenter St
West St
Cross St
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Roundhouse Ave
Bluebell Way
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Rougeot Pl
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Garfield St
Abbott St
Hays St
A e ro vista P ark
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C astillo Ct T a n g l e w o o d D r
S a n M arc o s C t
M
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Rose m ary Ct
S t e rlin g L n
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C o r o n a C t
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Richard St
Twin Ridge Dr
Arroyo Ln
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Sawleaf St
Spring Ct
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District 1 2 3 4 5
Population_B20 9136 9379 9276 9771 9597
% Deviation -3.14% -0.56% -1.65% 3.59% 1.75%
% LATPOP_B20 29.14% 17.16% 13.98% 14.69% 18.25%
% WHIPOP_B20 56.59% 69.68% 73.4% 70.32% 67.74%
% LATVAP_B20 25.46% 14.69% 12.31% 13.1% 16.45%
% WHIVAP_B20 60.6% 73.13% 75.46% 72.16% 69.52%
% lcvap_D21 21.33% 12.86% 8.53% 12.88% 17.55%
% wcvap_D21 70.21% 78.38% 82.14% 75.99% 70.33%
% bcvap_D21 1.46% 2.42% 1.92% 1.85% 2.84%
% acvap_D21 6.27% 5.54% 6.82% 7.7% 8.27%
% aocvap_D21 0.89% 0.8% 0.62% 1.69% 0.91%
Page 59 of 59
1
California Voting Rights Act Demand
Settlement Consideration
2
Recommendations
1. Approve a tentative settlement agreement and related settlement documents to resolve the February 17, 2023 California Voting Rights Act District Election Demand (CVRA Demand) served on the City by Kevin Shenkman on behalf of Southwest Voter Registration Education Project (SVREP), including:
a. Settlement Agreement
b. Draft CVRA Complaint to be filed by SVREP alleging CVRA violations
c. Draft City Answer to Complaint denying CVRA allegations
d. Stipulated judgment directing transition to Citywide Single Vote Council elections, beginning November 2026
2. Authorize the Mayor, City Attorney and City Manager to execute and file documents and take administrative actions necessary to implement the Settlement Agreement.
3. Appropriate $75,000 from the Fiscal Year 2023-24 General Fund Undesignated Fund Balance to be used for SVREP Attorneys' fees to date as described in the settlement agreement.
3
The California Voting Rights Act (CVRA)
Enacted in 2002 for the purpose of remediating any California at-large electoral system that had
the effect of diluting minority voting power because of racially polarized results
•Intended to increase opportunity of protected-class voters to elect chosen candidates or
influence the outcome of elections
The CVRA does not specify which remedies must be imposed
Single-member districts are a common remedy, but they are not mandated
Requires notice of an alleged violation (“demand letter”) to be provided to a public agency and
provides an opportunity to adopt an election alternative to address an alleged CVRA violation
before a lawsuit can be filed
•Statutory safe harbor against immediate litigation and limit on attorneys’ fees for agencies
that implement legally compliant district elections within specified time frames following
receipt of a demand letter; CVRA safe harbor time frames do not allow for robust public
outreach (steps to transition to district elections must occur within 90 days of a demand for
safe harbor provisions to apply)
4
Notice of Potential
Violation of the CVRA
The City of SLO has received two notices of potential violation of the CVRA
2019 notice from an individual voter was resolved by settlement in recognition of the City’s diversity goals and programs
A second notice received in 2023 from Southwest Voter Registration Education Program (SVREP) seeking structural change to the City’s current at-large electoral system
Both notices included a demand that the City transition to district elections
Both notices have been available for public review on the City’s website
5
City Response to Notices
Retained elections expert and demographer
Conducted demographic analyses as a basis to evaluate the potential merits of the demand and the efficacy of districts (first conducted in 2019 and updated following receipt of SVREP's CVRA demand letter)
Provided public notice of closed sessions, including publication of the CVRA demand letters served on the City as the basis for the anticipated litigation
Requested to meet with SVREP legal counsel, Mr. Shenkman and shared analytical conclusions and City’s DEI objectives and program actions aligned with CVRA objectives
Began outreach to local leaders in the affected Latinae community to understand potential impacts of the CVRA options on constituents, including priority needs, and local interest, preferences, and questions regarding various electoral structures
6
San Luis Obispo Demographics
The Latinae voter population in SLO is not sufficiently large or geographically compact to form a significant portion of the population in a single-member district
In a hypothetical five-district plan proposed by SVREP, concentrating the voting strength of Latinae voters, the strongest voter district for Latinae residents is just a bit over 20% (D-1).
See next
slide
7
SVREPExhibit D
Latinae voters in this District 1 are isolated from other Latinae voters in other districts who cannot work together to elect a chosen candidate or influence the outcome of elections.
The district does not properly consider the neighborhoods or communities of interest of the City
8
Shared Objectives
Enhanced voter equity and diverse candidate participation in local elections
Data based discussions and proposals regarding the most effective means to advance the purpose and intent of CVRA
Openness to consider viable alternatives to district elections that could more effectively advance CVRA objectives in SLO
Solutions that align with and advance SVREP’s voter empowerment goals and the City’s Diversity, Equity and Inclusion goals
Avoidance of solutions with unintended consequences that could adversely impact City progress toward DEI objectives
Enhanced voter education, outreach and engagement
SVREP’s primary objective to achieve a structural change in the City’s method of electing Councilmembers as a condition of any settlement, balanced with the City’s objective to respect its Charter and avoid overcorrection that could do more harm than good
9
Proposed Settlement Terms
The City Council has been in negotiations for nearly two years with
attorneys for SVREP to address its CVRA Notice. The following are the
final terms:
Transition to Citywide Single Vote electoral system in 2026 and
thereafter in which each voter votes for their preferred candidate
among all candidates running. The top two vote getters are elected
Commitment to education and outreach to enhance diverse
candidate development and voter education and participation
Data-sharing to track the effectiveness of the new system as
compared to SVREP Exhibit D
10
Proposed Settlement Terms
Ability of the City to implement district elections at any time and
thus be relieved of all obligations under the settlement
Transition to district elections if data analyses following the
2026/2028 elections does not demonstrate the effectiveness of the
new system as compared to Exhibit D
A dispute resolution process if the parties cannot agree on the
conclusions reached from 2026/2028 post-election data analyses
An expedited litigation path if the parties agree that data does not
demonstrate the effectiveness of the new electoral system and the
City chooses not to change to district-based elections
11
Proposed Settlement Terms
Payment of SVREP attorneys’ fees ($75,000) for its costs of
participation to date in negotiations with the City to avoid litigation
Agreement to limited payments to SVREP to offset its costs of
participation in future data analyses (not to exceed $10,000 per
election cycle)
Limitation on costs and plaintiffs’ attorneys’ fees to be borne by the
City related to agreed upon dispute resolution processes
No cap on plaintiffs’ attorneys’ fees if there is litigation
12
Why Citywide Single Vote
Voters would have one fewer vote than the number of Council seats
available (vote for one to elect two)
Top two candidates receiving the most single votes would be elected
No geographic barriers to selecting candidate of choice and Citywide
coalition building
Current practice for a significant number of voters
Prevents the same majority from controlling all of the available seats
13
Why Would Citywide Single Vote Work?
Candidate
Votes (percent)
Voting System A B C
“Plurality Bloc Voting” (PBV) 66(41)54(34)40(25)
Citywide Single Vote (CSV) 33(33)27(27)40(40)
Example provided by Michael Latner, Professor of Political Science, Cal Poly San Luis Obispo
14
Why Not Districts?
Concerns about effectiveness as CVRA remedy for SLO
Charter requires at-large elections
Potential unintended consequences in a small city, e.g. greatly reduced
candidate pool, reducing influence of Latinae community in City
governance
15
Why Not Ranked Choice Voting?
Cost & feasibility
Complexity
Voter confusion
Less experience with RCV in context of claims under the voting rights
act
16
Recommendations
1. Approve a tentative settlement agreement and related settlement documents to resolve the February 17, 2023 California Voting Rights Act District Election Demand (CVRA Demand) served on the City by Kevin Shenkman on behalf of Southwest Voter Registration Education Project (SVREP), including:
a. Settlement Agreement
b. Draft CVRA Complaint to be filed by SVREP alleging CVRA violations
c. Draft City Answer to Complaint denying CVRA allegations
d. Stipulated judgment directing transition to Citywide Single Vote Council elections, beginning November 2026
2. Authorize the Mayor, City Attorney and City Manager to execute and file documents and take administrative actions necessary to implement the Settlement Agreement.
3. Appropriate $75,000 from the Fiscal Year 2023-24 General Fund Undesignated Fund Balance to be used for SVREP Attorneys' fees to date as described in the settlement agreement.